Historic Districts Council Statement to NYC City Council on ZQA/MIH

The Historic Districts Council is the citywide advocate for New York’s historic neighborhoods. We represent over 500 neighborhood-based groups dedicated to preserving the physical character of their communities. Many of our constituents have spent years working with property owners, Community Boards, City Planning and elected officials to enact appropriate zoning in order to better protect the character of their neighborhoods and encourage new development which enhances where they call home. It is on their behalf that we address our very strong concerns about these proposed citywide zoning text amendments.

HDC echoes the numerous civic organizations and community boards citywide in our opposition to Zoning for Quality and Affordability (ZQA). ZQA is a wholesale upzoning of the entire city, and will not guarantee either goal of affordability or quality. There is no panacea for New York’s affordable housing crisis, and ZQA is not even a cure for its symptoms. Rather, it seems that ZQA is a concession to developers to sweeten Mandatory Inclusionary Housing (MIH). MIH is the only part of this proposal which might actually provide “affordable” units. ZQA loosens the entire city’s existing zoning to allow greater density for market-rate development, under the guise of creating affordable units, which, as we all know, is optional. The provisions for seniors have an expire after thirty years, after which will be converted to more market rate housing.

This upzoning amendment raises height limits and diminishes yard requirements across the city according to a mathematical nicety, without examining the built fabric of our city’s neighborhoods. Contextual zones came to fruition after years of effort by community-driven, carefully examined, neighborhood-specific studies. New York thrives because of the diversity of its neighborhoods, yet this proposal’s approach will deal with each neighborhood as the same, with a one-size-fits-all approach. A calculation of potential growth based on a model is not the same as actual development, especially when one considers the diversity of New York’s built environment. This potential impact will be consequential to contextually-zoned properties, as well as buildings in historic districts, where additional five feet will impact the uniform streets and pressure the LPC to approve taller buildings.

The Mayor’s administrative priority of our City’s housing crisis has been stated as two-fold: the creation and the preservation of affordable units. Thus far, the only push has been for creation, calling for a text amendment which will re-write our neighborhoods. There is a piece missing from this affordable housing armature, which is the preservation of units. ZQA might incentivize demolition of existing housing in order to replace it with new development utilizing the proposed as-of-right height limits. The success of MIH, as proposed, is dependent on upzoning, which encourage the demolition of existing building stock. Nearly half (47%) of all housing in New York City is rent regulated, which translates to approximately 1,025,000 units. Where is the plan for the preservation of these units? Smaller buildings which are 100% rent regulated should be identified and spared from ZQA, which could replace them with taller buildings with a 20% affordable component.

The notion that the City can only house people by relying on private investment with a market component lacks vision, while providing ZQA as relief for MIH is apologetic. HDC and civic leaders are grappling with what public good ZQA will actually provide, as an all-borough rezoning raises red flags, and is extremely rare. Further, MIH’s success is contingent on a massive upzoning on par with urban renewal, again as a plea to developers. This formula works under the assumption that affordable construction in New York will halt unless 200% bigger buildings with meager inclusionary units is the deal. In a housing crisis, why not demand 100% affordable units in rezoned areas and a percentage of affordable units on all new construction? Bigger buildings do not equal lower rents, if that were the case, West 57th Street would be Manhattan’s newest neighborhood for the middle class.

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